- Information provided under the website or sites: Occasionally, we may use certain information that we have collected to send You information about programs or services offered by Manipal, its partners, authorized representatives.
If you are providing PI or SPDI and are not a resident of India, your country’s laws governing data collection and may use differ from those in India, in particular, the India may not provide the same level of protection as those in your own country. By providing information to Manipal, you are transferring your personal data (including PI and SPDI) to the India, and you consent to the transfer to, retention of and processing of your data in the India.
2.1 You agree and confirm that Manipal may collect, store, process, disclose and transfer the SPDI collected about you to any of its affiliates, agents or third party service providers in connection with the products and services or courses you have sought from, or to provide better services to you or to ensure compliance with a legal or contractual obligations of Manipal. The purpose for which Manipal would collect and use your SPDI includes instances set out in clause 3.2 below. The types of third parties (whether in India or abroad) that your SPDI could be disclosed to, includes the types of third parties mentioned in clause 5 below. You confirm that the SPDI so far collected, stored, processed, disclosed and transferred by Manipal in the course of your engagement for the above purposes shall continue to be used by Manipal strictly in accordance with the applicable laws.
2.2 Personal Information (the “PI”) for the purposes of this Policy, refers to any information that relates to a natural person which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person such as name or address and to be read with the relevant internal policies including that of its associates and subsidiaries or group companies of Manipal.
2.3 Sensitive Personal Data or information of a person (the “SPDI”) for the purposes of this Policy, shall be the same as defined in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI”) Rules, as amended from time to time; i.e
(ii) Financial information such as bank account or credit card or debit card or other payment instrument details;
(iii) Physical, physiological and mental health condition;
(iv) Sexual orientation;
(v) Medical records and history;
(vi) Biometric information;
(vii) Any detail relating to the above clauses as provided to us for providing services; and
(viii) Any of the information received under any of the above clauses by us for processing, storing or processing under lawful contract or otherwise.
Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Policy.
2.3 Information Provider
For the purposes of this Policy, refers to a natural person or individual who provides PI or SPDI to Manipal. In this Policy, the Information Providers are referred to as ‘You’.
2.4 Links to third party sites
3. Purpose of collection and use of SPDI
3.1 Manipal will ordinarily collect PI (including email addresses, phone numbers, business and home address, as well as demographic information such as courses or areas of study in which you may be interested) or SPDI that it believes is necessary for any purpose connected with a function or activity necessary to deliver, promote or market services or to carry out primary business functions and/or activities, comply with applicable regulations or in capacity as an employee or a counterparty to agreement with individuals. Ordinarily, Manipal will collect such PI or SPDI about You when You provide it or You have consented to provide the information or where it is required by law, as applicants, through online registration forms, as well as offline, through assessment, events, survey respondents. To the extent that information requested is not required for your participation in a given Manipal program / course, you will be told which information is optional. Should you fail to provide optional information certain Manipal programs or features of the site may not be available to you.
3.2 In general, we would be collecting / handling/ storing /using or transferring your SPDI for the following, including but not limited to:
3.2.1 complying with legislative and regulatory requirements
3.2.2 providing agreed services to You;
3.2.3 performing administrative functions; and
3.3 The SPDI collected from You may be collected and/or retained either directly by Manipal or through or with an affiliate or third party.
Manipal, its affiliates and third parties it shares SPDI with, will retain the SPDI for a reasonable period for the purposes for which such information has been collected and as may be lawfully used or is otherwise required under any law for the time being in force.
The SPDI collected shall be used for the purpose for which it has been collected.
You have the option not to provide Manipal with the SPDI sought to be collected. You also have the option to withdraw the consent given earlier, provided it is sent to us in writing. In the event SPDI which Manipal deems necessary for providing you with any service is not provided or if consent is withdrawn subsequently, Manipal reserves the right not provide you with such services / benefits / amenities and take any other action in this regard on just and reasonable grounds.
We may also use your PI to tailor your experiences at our sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to such preferences.
4. SPDI about third parties
While providing SPDI of another natural person (particulars of spouse, children or parents) to Manipal, please ensure that you have the necessary concurrence of that natural person.
5. Disclosure of Sensitive PI
5.1 In general, Manipal will not use or disclose SPDI collected about You to a third party otherwise than for the purposes set out in this Policy, unless the disclosure is necessary for compliance of a legal obligation or where it is agreed to in the contract with you or as consented by you and supported by a valid non-disclosure contract or provisions in the legal contract.
5.2 Provided that such information shall be shared with your consent, with government agencies mandated under law to obtain information including SPDI for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences or any law enforcing authorities.
5.3 Notwithstanding anything contained in the preceding paragraphs of this section, any SPDI shall be disclosed to any third party by an order under a law for the time being in force.
5.4 You authorize Manipal to disclose necessary SPDI to certain employees, consultants, employees or consultants, of Manipal affiliates, agents or third party service providers within India or outside India who provide services to Manipal in connection with the education services you have sought from, or, your employment with, Manipal, on a need-to-know basis. These parties shall use your SPDI only for the specific purpose for which Manipal supplies the SPDI to them and from disclosing it further. Manipal may share PI or SPDI with third parties for legitimate business purposes, including for the following reasons or in the following circumstances:
- To vendors or third-parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of Manipal, which third parties include, for example training providers and partners, third party event hosting sites, other third parties who may provide services on web sites that are accessible from links on one of the website and credit card companies processing payment;
- To Manipal employees, officers and directors;
- To Manipal partners, program coordinators;
- If you are attending an event as attendee or speaker, certain of your information will be included in the event calendar which may be publicly disclosed, and may also be shared with third party event sponsors and exhibitors;
- If you use any our career center services, your information may be accessible to potential employer or recruiters;
- To those who wish to determine if you are certified, your certification status will be shared with those who inquire;
- To investigate potentially fraudulent or questionable activities or transactions;
- In anticipation of an in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of our business operations; and
- When we believe it is necessary to cooperate with law enforcement or in response to a government request, including if specifically requested or required, as otherwise permitted by law, and for other valid Manipal business purposes.
Manipal also may use your PI on an aggregate basis-without PI – to provide third parties with information, such as to help us develop new features and content for the Sites, and to provide and other with aggregate information about our users and the usage patterns of the sites.
5.5 Subject to what is permitted by law, the types of third parties (whether in India or overseas) your SPDI could be disclosed to may include:
5.5.1 agents, contractors, service providers, insurers and external advisers engaged by Manipal from time to time to carry out, provide services or advise on the functions and activities;
5.5.2 other related bodies corporate /affiliates of Manipal;
5.5.3 any person or organization who introduces you to Manipal;
5.5.4 regulatory bodies, government agencies, law enforcement bodies and courts;
5.5.5 any person or organization who Manipal deems necessary for carrying out the instructions you give to Manipal; and
5.5.6 any prospective transferee in a scheme of arrangement, amalgamation, merger or sale of shares or sale of business relating to the whole or part of Manipal.
6. Transfer of Sensitive Personal Information
Manipal may transfer your SPDI to any person or entity, whether in India or located in any other country, that ensures a similar level of data protection as Manipal employs when it is necessary for the performance of a lawful contract with you or where you have consented to such transfer.
8. Access to your Sensitive Personal Information
You may review and correct or revise the SPDI you have provided to us for the purpose of ensuring the said information is accurate. Manipal shall not be responsible for the authenticity of the information you have supplied to it or to any person acting on its behalf.
9. Information Security Standard for SPDI at MANIPAL
Manipal operates in an environment that is similar to the requirements of ISO/IEC 27001 Security Standards for ensuring that the SPDI it holds is protected from misuse, loss and unauthorized access, modification or disclosure. Manipal may use Secure Socket Layer (“SSL”) or Transport Layer Security (“TLS”) encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the information under Manipal control.
Manipal cannot guarantee, however that your information will remain secure. The internet by its nature is a public forum, and Manipal encourages you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.
10. Non-Personal information gathered automatically / passively though common tracking tools
- The Internet domain or internet service provider for your internet service, Browser type, type of computer, the operating system platform, date / time stamp, referring / exit pages address of the previous website that you were visiting, if you linked to us from another website, domain name and country/state and other similar information.
- IP address to help diagnose problems with servers that host and administer our website.
- Our website might contain links to third party websites. We do not have control and are not responsible for, the content, privacy policies or reliability of such sites.
We use this information for statistical analysis, to help us make our site more useful to visitors. This tracking system does not record information about individuals.
If you do not want to have cookies placed on your device, many of them offer ways to opt-out. Where possible, we have provided a link that explains how to opt-out of that third party serving out cookies.
Below are some information about tracking tools and cookies we currently use on the website or our sites. We use these tools to improve the website or our sites and experience of our visitors:
- Google Adwords Conversion: We use conversion tracking to help us understand how effective our digital campaigns are.
- Google Analytics: We use to collect information about how visitors use our website. For example, we collect details of the website or sites where the visitor has come from and the total number of times a visitor has been to our website. This allows us to determine the effectiveness of our online campaigns in terms of sales and user activity on our sites.
The information generated by the cookie about your use of the website includes your IP address. This information will be transmitted to and stored by Google or third party on its servers. Google or third party will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to Internet usage. Google or third party may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s or third party’s behalf. Google or third party will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google or third party in the manner and for the purposes set out above.
We collect PI about users over time and across different web sites when you use the website or Services. We have also third parties that collect PI this way. To do this we use several common tracking tools. These may include browser cookies. We may also use web beacons, flash cookies and similar technologies. Our vendors might use these tools. Web beacons are often used in conjunction with cookies to help the website understand its users better. When we send you newsletters or other message, we use these technologies to determine a users’ ability to receive HTML e-mail in addition to whether or not an e-mail has been opened. A web beacon (actually a small .gif image) is activated when an HTML e-mail is opened via a request for the image on our servers. This capability helps Manipal send e-mail in a format that users can read and enables Manipal to track the aggregate number of e-mails opened. The web beacon does not collect any PI. Users who do not want to receive e-mail messages with web beacons can choose to receive their e-mails in text (non-HTML) format.
Interest-based advertising. We are our partners display interest based advertising using information gathered about you over time across multiple websites or other platforms. This might include apps. Interest based advertising or “online behavioral advertising” includes ads served to you after you leave the website, encouraging you to return. They also include ads we think are relevant based on your browsing habits or online activities. These ads might be served on websites or on apps. They might also be served in emails. We might serve these ads, or third party may serve ads. They might be about our products or other companies products and services. Where legally required we get consent to engage in interest-based advertising.
To decide what is relevant to you, we use information you make available to us when you interact ith us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your purchases or browsing behaviors. We might look at these activities on our platforms or the platforms of others. We work with third parties who help gather this information.
Updating your personal information and privacy preferences
You have the right to access, correct and delete inaccuracies in your personal information and privacy preferences at any time. With respect to Registration Information (as defined in the section entitled "Protection of your personal information"), this may be accomplished by logging in to your account on the relevant website, where you can typically view and make changes to your personal information. You may also access and correct your personal information and privacy preferences (such as whether you wish to receive promotional communications of Manipal, and its affiliates within the Manipal Global Education framework) by writing to Support Team, Manipal ProLearn, C/o Manipal Global Education Services Private Limited, Manipal Towers, No.14, Old Airport Road, Bangalore-560038.
Collection of personal information
As a visitor to this website, you can engage in many activities without providing any personal information. In connection with other activities, such as utilizing online or hosted Programs and Services, Manipal may ask you to provide certain information about yourself by filling out and submitting a form. It is optional for you to engage in these activities. If you elect to engage in these activities, however, Manipal may ask that you provide certain personal information (as well as certain non-personal information that may be tied to personal information), such as your first and last name, mailing address (including ZIP code), country, e-mail address, employer, job title and department, and telephone and facsimile numbers,. Depending upon the activity you intend to use on some Manipal Services and Programs that you have enrolled, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. Similarly, if you wish to delete your information that is mandatory, you will no longer be able to engage in that particular activity.
If you decide to send us an electronic mail message (e-mail), the message will usually contain return e-mail address. If you include, personally-identifiable information in your e-mail, because you want us to address specific to your situation. We may use that information in responding to your request, e-mail is not necessarily secure against interception. Please send us only information to help us process your request for the specified service.
Personal Information that users provide about other individuals for tell-a-friend or other referral features on the Site or within Programs and Services is used by Manipal to send an initial communication to the person whose details you have provided, and is not retained in Manipal’s systems. If you are invited by someone else to participate in shared editing or viewing of documents, photos, websites or other content, you will typically be required to contact the person who invited you to update, correct or delete the personal information they provided about you. In general, even though we may delete an account you hold with us in these types of shared editing or viewing areas, we may continue to retain information regarding your past actions with respect to content reviews or sharing initiated by others.
We may also ask you to provide information of others such as when reporting suspected piracy. In this instance, we will ask for the person's or company's name and contact information so that we may investigate. Personal information supplied in these instances will only be used for the purpose being submitted.
Manipal also hires other companies to place our banner ads on other websites. Such companies perform tracking and reporting activities on ads served and user reaction ("third-party advertisement servers"). They do not collect any information other than IP addresses and behaviours associated with those IP addresses on our behalf, and we do not give any personal information to them. Third-party advertisement servers are subject to their own privacy policies. Manipal may also allow other companies to display advertisements on certain pages of the Site or within the Programs and Services. If you click on these advertisements these companies may place a persistent cookie on your computer which may allow them to display further advertisements to you. It is our policy to require these companies to provide accessible methods for you to disable these cookies.
Manipal reserves the right, at its sole discretion, to review, edit or any material posted by users which Manipal deems defamatory, unlawful, threatening, obscene or otherwise objectionable. Notwithstanding the foregoing, Manipal Global Education expressly disclaims any responsibility or liability for any material communicated by third parties through this web site.
11. Grievance handling
You may contact the Grievance Redressal Officer (GRO), who is the designated grievance officer, for any grievances with respect to processing your Sensitive Personal Information. Manipal will make every effort to resolve your grievance expeditiously.
Name of GRO: Mr. Krishna Swami Mohan
This Policy is updated on May 26, 2017